Mathura Mercantile P. Ltd. v. PCIT (2022) 213 DTR 433 / 326 CTR 606(MP)(HC)

S. 148A : Reassessment Notice-show cause notice before passing the order-Petitioner within a period of four days submitted reply-the petitioner cannot challenge the notice on the ground that clear seven days’ time was not afforded-Writ petition was dismissed. [S. 148, Art, 226]

Held that, on receipt of the notice, without any object or protest, the petitioner filed its reply on merit therefore, the petitioner cannot question the issuance of show cause notice alleging contravention of s. 148-A. The petitioner was bound by the principle of waiver having responded to the show cause notice with a detailed and voluminous reply to the show cause, thus, after submission of the reply, cannot be alleged that the notice was against the provisions incorporated in S.148-A.  The writ petition was dismissed.